The tax classification of a foreign pension fund investing in the United States has major implications in terms of who is subject to tax, the applicable tax rate and the associated reporting obligations. Francis Helverson of WTS explains why pension funds with certain characteristics may have significant advantages over other pension funds as well as over other types of foreign investors.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting